We are troubled by reports that you are considering appointing to top positions, including Deputy
Administrator and Assistant Administrator for Prevention, Pesticides, and Toxic Substances,
individuals with substantial previous ties to agricultural biotechnology companies. As you know,
biotechnology is a highly controversial issue and an area in which the EPA must be, and be perceived
as being, completely objective and impartial. Even in cases in which an individual is highly qualified
for the position, a real or perceived conflict of interest would further decrease public confidence in the
agency and its regulation of biotechnology. Also, controversy concerning the regulation of
agricultural biotechnology has resulted in a huge loss of trade in genetically engineered crops.
Appointment of anyone with ties to the regulated industry would only exacerbate tensions with our
trading partners.

We commend President Bushs oft-stated goal of adhering to high ethical standards. Appointing
high-level officials with real or perceived conflicts of interest, in the regulation of agricultural
biotechnology or other matters, would be contrary to those goals. Though appointees with conflicts
might recuse themselves from decisions related to biotechnology, such a solution would diminish the
value of those employees and would be unlikely to quell legitimate doubts about the broader influence
of such an individual on EPA's biotechnology policy.

Therefore, we urge you not to appoint individuals with conflicts of interest concerning biotechnology
or other issues over which they would preside. Qualified individuals without such conflicts can
surely be found.